1.General rules concerning obtainment

EFFECTIM Company, Limited (hereinafter, the “Company”) may ask for personal information from customers and the related persons of business acquaintances, etc. as necessary and store, manage, and use such personal information. If the Company obtains personal information, as a general rule, the Company will clarify the purpose of use and “scope of use” in advance and inform the person concerned of the same together with the “Company Support Desk” etc., and obtain personal information within the scope necessary to achieve the purpose of use, and take steps to prevent the use of such personal information for other purposes.
In the event of obtaining personal information that requires special care, the Company will, unless otherwise permitted by law, obtain the prior consent of the person concerned.

2.General rules of appropriate management

The Company will manage personal information in accordance with appropriate methods. Unless otherwise prescribed by laws and regulations, etc., as a general rule, the Company will not disclose nor provide personal information to third parties without the permission of the person concerned.

3.Outsourcing of the handling of personal information to business partners

If the Company needs to entrust personal information in its possession to a business partner as a result, for example, of outsourcing operations that involve the handling of personal information, the Company will carefully select a trustworthy business partner, and execute a contract with such business partner that requires such business partner to manage the information appropriately as specified by the Company.

4.Ensuring accuracy and security

The Company will keep the personal information in its possession accurate and updated, and take steps to prevent the divulgation of, destruction of, or damage to personal information, and take remedial actions in the case that such circumstances do occur.

5.Complaints and inquiries concerning personal information

If a customer directs any complaints and inquiries concerning the handling of personal information to the Company Support Desk, it will respond promptly.

6.Personal information of minors

The Company will protect the personal information of minors in the same manner that it protects the personal information of adults. In the case of persons under sixteen (16) years of age, the Company may handle the information in various ways as necessary upon obtaining consent from their parent or guardian, together with seeking confirmation and obtaining consent from the person concerned.

7.Compliance with laws and regulations

The Company will comply with laws and regulations, guidance prescribed by the national government and other norms, and industry guidelines, etc. applicable in relation to personal information.

8.Purpose of use of personal information

(1) In the event that the Company obtains personal information, as a general rule, the Company will expressly indicate the purpose of use and the scope of use by methods such as in writing, website screen, or orally each time.
(2) The Company may omit express indication of the purpose of use if the purpose of use of the personal information is clear, such as in the case of asking for contact details in order to respond to a question or request, etc. from a customer, or in the case of exchanging name cards in accordance with business customs. Even in such cases, as a general rule, the personal information obtained will be used within the scope of the following purposes of use.
(3) The Company will use the personal information from customers, related persons of business acquaintances, etc. for the following purposes:
① To appropriately respond to inquiries, reservations, consultations, etc. from customers;
② To provide services such as skin diagnosis etc. implemented through the apps at the brick-and-mortar shops or on the websites (hereinafter, the “Skin Diagnosis Services”);
③ To conduct business negotiations with related persons of business acquaintances and to communicate in accompaniment with such business negotiations;
④ To send greeting cards, etc. to customers and related persons of business acquaintances;
⑤ To introduce products, campaigns, and events;
⑥ To conduct questionnaire surveys and analyze statistical data in order to develop products and improve services;
⑦ To communicate other required matters.
(4) In the event that the Company makes any changes to the aforementioned purposes of use beyond the scope deemed to be reasonably related, the Company will obtain consent by methods such as in writing, website screen, or orally each time.
(5) Although the registration or provision of personal information is on a voluntary basis, if a customer fails to register or provide items of information that are required for the provision of certain services, such customer may become unable to use various services provided through the Website (hereinafter, the “Services”).
(6) The Company will jointly use the personal information of customers as follows:
① The items of the personal information to be jointly used
The following personal information obtained by the Company for the purposes of (3)② above
1.Customer information such as name, gender, age, etc.;
2.Skin images and movies data shot through the Skin Diagnosis Services;
3.Other information provided by customers in relation to the Skin Diagnosis Services.
② The scope of the jointly using parties
・ The Company and Shiseido Company, Limited;
・ The overseas affiliated subsidiaries of the Company and Shiseido Company, Limited;
・ Skin Diagnosis Services development companies.
③ The purposes of use of joint use
・ To provide services (including the services mentioned (3)② above) of the jointly using parties;
・ To introduce products, services, campaigns, events, etc. of the jointly using parties;
・ To develop or improve products, services, campaigns, events, etc. of the jointly using parties;
・ To respond to customer inquiries
④ The name of the parties responsible for managing the personal information of customers
EFFECTIM Company, Limited and Shiseido Company, Limited

9.Provision of personal information to third parties

The Company will appropriately manage the personal information it has obtained, and unless permitted by laws and regulations (including the case that the Company entrusts the development, operation, and maintenance of this website to a company located in China, including its affiliates and contractors upon establishment of “a system conforming to standards prescribed by rules of the Personal Information Protection Commission” under Article 24 of Act on the Protection of Personal Information), the Company will not provide such personal information to third parties without the prior consent of the person concerned.

10.Anonymized information

In the event that the Company processes personal information to produce anonymized information, the Company shall implement the same by following appropriate procedures in accordance with laws and regulations related to the protection of personal information, and regarding the secure management of anonymized information, the Company will take the required security measures similarly as those for the secure management of personal information, and appropriately review these measures. In the event that the Company provides anonymized information to a third party, the Company will implement the same by following appropriate procedures in accordance with laws and regulations related to the protection of personal information.

11.Use of Cookies and web beacons

The Website employs Cookies for certain contents for the following purposes. The function of Cookies on the Website is to store, on the customer’s own computer, the information that a customer has viewed the Website, and the information gathered by using the Cookies will not include any “information that could be used to identify the individual” such as their email address or name.
(1) In the case of an application that covers multiple pages on the Website, for the purpose of temporarily storing required information to make the Website more convenient to view;
(2) When a customer is logged in to a service requiring authentication, for the purpose of referencing the customer’s stored registration information to enable the provision of the services that are customized for each customer;
(3) For the purpose of providing better services through the Website by enabling the Company, or companies to which the Company outsources research and analysis, to analyze customer access trends on the Website;
(4) For the purpose of showing customers the most appropriate advertisements on other companies’ websites based on what such customers are interested in and the status of use of the Website by such customers;
(5) For the purpose of maintaining security by having customers re-enter their passwords (perform re-authentication) after a certain period of time has elapsed since their use of the Website.
The Company may allow companies to which it outsources advertisement distribution to store and reference Cookies for the Website through the websites of such outsourcee companies. In order for sufficient use of the Services by customers, it is a condition that the customers consent to the use of Cookies by the Company etc. and the acceptance of Cookies. Although customers are able to set their browsers to reject Cookies, in such case, such customers accept in advance that some of the content may not function properly or may become unusable.
Certain pages on the Website employ a technology called web beacon to gather statistics on customers’ use of the Services. Customers’ personal information is not gathered by web beacons. Customers may also block web beacons from obtaining information by setting their browsers to reject Cookies.

12.Disclosure etc. of personal information

The Company will respond appropriately to the requests by the persons concerned which are related to the notification of the purpose of use of personal information, as well as the disclosure of, amendment of, additions to or deletion of, suspension of use of, removal of, and suspension of provision to third parties of, personal information.
To make such a request, please contact the Company as mentioned in “14. Inquiries concerning personal information.”

13.Person responsible for the management of personal information

Regarding the handling of personal information, a person responsible for the management of personal information is appointed, and the information is appropriately protected, managed and used in accordance with instructions from such person responsible for the management of personal information. The person responsible for management of personal information of the Company is the President.

14.Inquiries concerning personal information

Please contact the following for any complaints or inquiries concerning the Company’s handling of personal information:

Address: 5-5, Ginza 7-chome, Chuo-ku, Tokyo 104-0061, Japan
Tel: 03-6218-6500
https://corp.shiseido.com/en/inquiry/

15.Other

The “Privacy Policy of EFFECTIM Company, Limited” shall be governed by and construed in accordance with the laws of Japan.

Issued on January 1, 2021